“One need not be xenophobic to be troubled by the idea of foreign influence in American elections. Certainly the Framers were. The point is not that foreigners are evil. It is rather that elections are private. It is we — citizens — who are to select who is to govern us. And it is completely appropriate for us to protect the debate we have about that selection by limiting disproportionate spending by non-citizens. This insight gives a clue to perhaps the most sensible constitutional response to the Supreme Court’s decision. Not, as an angry gaggle of activists have proposed, through an amendment aimed at denying what Citizens United never asserted — that corporations are persons. But instead, through an amendment that recognizes what no one has ever asserted — that whether or not they are persons, corporations are not United States citizens.” (03/16/10)